Privacy Policy

1. Who we are

589 Group LLC is a sales diagnostics and revenue performance company based in Houston, Texas, United States. We provide sales force evaluations, hiring assessments, sales manager coaching (including the 2mm Club), and related advisory services.

2. Our two roles: controller and processor

We handle personal information in two different capacities, and this policy treats them differently.

When we act as a controller. For information about visitors to our Sites, people who contact us, subscribers, event attendees, podcast guests, and the business contacts we work with, 589 decides how and why the information is used. This policy applies in full to that information.

When we act as a processor for our clients. When a client engages us to evaluate its sales team or assess candidates for employment, the client (usually the employer) is the controller of that information. We process it only on the client's documented instructions, under a written agreement and data processing addendum with that client. Assessments are delivered through a platform operated by Objective Management Group ("OMG"), which acts as our sub-processor. If you were assessed through one of our clients, that client's privacy notice governs how your results are used, and you should direct requests about your assessment data to that client. We will help the client respond. More detail on assessment data is in Section 6.

3. Information we collect

Information you give us

Contact and inquiry details: name, email address, company, job title, phone number (if you choose to provide it), and the content of your message when you fill out a form or email us.

2mm Scorecard and other tools: your answers to the scorecard or calculator questions, together with the contact details you enter to receive your results.

Booking details: name, email address, company and any notes you add when you schedule a call with us.

Subscription details: your name and email address when you sign up for our emails or newsletter.

Program and client details: for 2mm Club members and clients, billing contact details, company information, session scheduling details and information you share with us during coaching or engagement work.

Podcast guest details: name, title, company, biography, photo, and the audio and video of the recorded conversation.

Payment details: billing name, company and address. Payments are handled by our banking and payment providers; we do not store full card or bank account numbers on our own systems.

Information collected automatically

When you visit the Sites, we and our service providers may automatically collect IP address, browser type, device type, operating system, referring page, pages viewed, time on page, and approximate location derived from IP address. We collect this through cookies, pixels and similar technologies (see Section 9).

When you open or click on our emails, our email providers may record that activity so we can understand what is useful and keep our lists clean.

Information from other sources

We may receive business contact information (such as name, title, company and business email address) from professional networking sites such as LinkedIn, from business data providers, from event organizers, and from people who refer or introduce you to us.

Information we do not want

We do not ask for, and ask you not to send us, government identification numbers, financial account numbers, health information, biometric information, or other sensitive personal information.

4. How we use information

We use personal information to:

• respond to your inquiries and schedule conversations;
• deliver the scorecard, calculator and other resources you request;
• provide our services and programs, including the 2mm Club, and manage client relationships;
• send emails and newsletters you have signed up for, and relevant business communications to professional contacts (you can unsubscribe at any time);
• produce, publish and promote the Sales, Actually podcast, with the agreement of our guests;
• invoice, collect payment and keep business records;
• understand how the Sites are used and improve them;
• measure the performance of our marketing, including on LinkedIn;
• protect the security of our Sites and systems and prevent fraud or misuse; and
• comply with legal obligations and enforce our agreements.

5. Legal bases (for visitors in the EEA, UK and Switzerland)

Where the GDPR or similar law applies, we rely on: performance of a contract (to provide services and programs you or your company have engaged us for); legitimate interests (to run and improve our business, communicate with professional contacts, and keep our systems secure, balanced against your rights); consent (for certain cookies and marketing where the law requires it, which you can withdraw at any time); and legal obligation (for tax, accounting and other legal requirements).

6. Assessment data

Assessment data includes the name, email address, sales experience details and current position of the person being assessed, their responses to assessment questions, the findings and reports generated from those responses, and device data such as IP address and browser type.

For assessment data:

• The client is the controller. The client decides who is assessed and how results are used. We act only on the client's instructions.
• Assessments run on OMG's platform, hosted on Microsoft Azure in the United States, with data encrypted in transit and at rest. OMG's own privacy policy is available at www.omghub.com/omg-privacy-policy.
• Access is restricted to named 589 personnel who are bound by confidentiality obligations and have executed a non-disclosure agreement with OMG. Multi-factor authentication is enforced.
• Results go to the client. Results for a client's existing employees are shared with the employee, their manager, and the people the client designates. Results for job candidates are shared with the client only.
• Assessment data never enters our marketing systems. It does not pass through our customer relationship management, email marketing or prospecting tools.
• De-identified research. OMG uses assessment responses that have been stripped of personal information and aggregated with other responses for research and to improve its platform. This does not involve identifiable information.
• Retention is set in the client agreement. By default, records for a client's existing employees are kept for the engagement term plus 24 months, and candidate records are kept for one year after the client's hiring license expires. Working copies on 589 systems are deleted when the final readout is delivered.
• Requests. If you contact us or OMG directly about assessment data, we will refer you to the client that arranged your assessment and let that client know, so it can respond as controller.

7. Artificial intelligence and meeting notes

We do not sell personal information, and we do not use it to train artificial intelligence or machine learning models.

We may use AI tools to help prepare analysis. We do not submit identifiable assessment data to generative AI services. Participant identifiers are removed first, and the providers we use are contractually prohibited from training their models on that data.

We may use an AI notetaking service in discovery and working sessions. When we do, we tell participants at the start of the session. We do not use notetakers in individual assessment results sessions, and we do not record client sessions on our own systems. If a client wants a recording, the client makes and keeps it. Podcast conversations are recorded only with the guest's agreement.

8. How we share information

We do not sell personal information. We share it only as described here:

• Service providers who help us run our business under contracts that limit their use of the information, including providers of email and document storage (Google Workspace), website hosting and development, customer relationship management, email marketing and delivery, appointment scheduling, meeting notes, AI-assisted analysis, podcast recording and distribution, banking and payments, and accounting.
• Objective Management Group, as our assessment platform provider, for assessment data (see Section 6).
• Clients, who receive the assessment results they are entitled to under their agreement with us.
• Delivery partners, where another firm delivers an engagement jointly with us and you are involved in that engagement. We do not share individual assessment results with a delivery partner unless the client has directed us to.
• Podcast audiences, when a guest has agreed to appear on a published episode.
• Legal and safety reasons, when required by law, subpoena or court order, or to protect the rights, property or safety of 589, our clients or others.
• Business transfers, if 589 is involved in a merger, acquisition or sale of assets, in which case personal information may transfer subject to this policy.
• With your direction or consent.

9. Cookies and similar technologies

We use cookies and similar technologies to keep the Sites working, understand how they are used, and measure our marketing. These may include analytics tools and advertising measurement tools such as the LinkedIn Insight Tag.

You can block or delete cookies through your browser settings. Blocking some cookies may affect how the Sites work. Where the law requires consent for non-essential cookies, we ask for it first. We treat a Global Privacy Control signal from your browser as a request to opt out of any use of your information for targeted advertising.

10. Your choices

Email: every marketing email includes an unsubscribe link. You can also email kk@589inc.com. We may still send you messages related to services you have engaged us for.

Cookies: see Section 9.

Podcast: guests can contact us about their episode at kk@589inc.com.

11. Your privacy rights

Depending on where you live, you may have the right to:

• know what personal information we hold about you and access a copy;
• correct inaccurate information;
• delete your information;
• receive your information in a portable format;
• opt out of targeted advertising, the sale of personal information, and profiling that produces legal or similarly significant effects;
• object to or restrict certain processing; and
• withdraw consent where we rely on it.

Residents of Texas, California and other U.S. states with privacy laws, and individuals in the EEA, UK and Switzerland, have rights along these lines. We extend these rights to everyone regardless of location, subject to legal limits.

How to make a request. Email kk@589inc.com with the subject line "Privacy Request." We will need to verify your identity before acting on your request. You may use an authorized agent, and we may ask for proof of their authority. We respond within 45 days (or within one month where the GDPR applies), and we will tell you if we need more time as the law allows.

If we decline your request, you can appeal by replying to our decision with the subject line "Privacy Appeal." We will respond to appeals within 60 days. If your appeal is denied, you may contact your state attorney general (for Texas residents, the Office of the Texas Attorney General at www.texasattorneygeneral.gov) or your local data protection authority.

Assessment data requests are handled through the client that arranged your assessment (see Section 6).

We will not discriminate against you for exercising your rights.

12. How long we keep information

We keep personal information only as long as needed for the purposes described in this policy:

• inquiries and scorecard submissions that do not lead to a relationship: generally up to three years from our last contact, unless you ask us to delete them sooner;
• email subscribers: until you unsubscribe, after which we keep a suppression record so we do not email you again;
• client and program records: for the relationship plus the period needed for tax, accounting and legal purposes (generally seven years);
• assessment data: as set in the client agreement (see Section 6); and
• podcast recordings and published episodes: for as long as the episode is available.

13. How we protect information

We use reasonable administrative, technical and physical safeguards, including multi-factor authentication on our business systems, encryption in transit, full disk encryption on devices that hold client working files, restricted access on a need-to-know basis, and written confidentiality obligations. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

If we become aware of a security incident affecting personal information, we will notify affected clients and individuals as required by law and by our client agreements.

14. International data transfers

589 is based in the United States, and we and our service providers store and process information in the United States. If you are located outside the United States, your information will be transferred to the United States. Where required, we rely on appropriate safeguards such as the EU-U.S. Data Privacy Framework (including the UK Extension and Swiss-U.S. framework, where our providers participate) or Standard Contractual Clauses.

15. Children

Our Sites and services are intended for business professionals and are not directed to anyone under 18. We do not knowingly collect personal information from children. If you believe a child has provided us with information, contact us and we will delete it.

16. Links to other sites

The Sites may link to third-party websites and services, such as LinkedIn, YouTube, podcast platforms and scheduling tools. Their privacy practices are governed by their own policies, not this one.

17. Changes to this policy

We may update this policy from time to time. When we do, we will change the "Last updated" date at the top. If a change is significant, we will provide additional notice, such as a notice on the Sites or an email to clients.

18. Contact us

589 Group LLC
Houston, Texas, United States
Email: kk@589inc.com

For our mailing address, please email us at kk@589inc.com.